BD Speeches

This enforcement action misapplies the statutory definition of “broker,” further muddies an already confusing landscape created by prior staff no-action letters issued to firms engaged ...

"It’s interesting to note that the United Kingdom, Canada, and Australia don’t allow broker-dealers to route retail orders to wholesalers in return for payments .... Again, it’s best ...

"Best execution is a nuanced concept .... Of course, no discussion of best execution in the current market environment can disregard the incentives created by ...

Broker-dealers have a legal duty to seek to obtain best execution of customer orders....for several years now I have advocated for the Commission to provide ...

"Failure to have adequate written policies and procedures and failure to have adequate supervisory and compliance oversight may indicate recurring issues in complying with Regulation ...

While CAT has been firmly established as an operational regulatory reporting system, 2021 will be another important year of milestones for CAT, with transaction reporting, ...

I am not convinced, however, that these protections are adequate given the potentially high stakes of any conditions or restrictions for the viability of a ...

"It should not provide a grace period for compliance with clear violations of law -- especially violations that put investor funds directly at risk.  Here, ...

The net result of these changes would be a more secure CAT, operating without sensitive PII

I would have preferred the bolder step of confronting the CAT’s real and serious liberty implications